RECREATIONAL
FISHING AND
BOATING INDUSTRY
SUBMISSION ON THE SOUTH-WEST MARINE
BIOREGIONAL PLAN (DRAFT) AND PROPOSAL
FOR THE SOUTH-WEST COMMONWEALTH
MARINE RESERVES NETWORK (DRAFT)
Compiled by the Boating and Fishing Council of Australia
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CONTENTS
Contents .............................................................................................................................................................................................. 1
Executive Summary ............................................................................................................................................................................. 2
Purpose Scope and Objective ............................................................................................................................................................. 4
General Comments ............................................................................................................................................................................. 5
Fisheries Adjustment Policy ................................................................................................................................................................ 6
The Plan .............................................................................................................................................................................................. 7
Distinguishing recreational from commercial fishing ..................................................................................................................... 7
Expansion of recreational fishing effort.......................................................................................................................................... 8
Ecosystem impacts of fishing .......................................................................................................................................................... 8
Impacts of fishing on protected species.......................................................................................................................................... 9
Habitat modification and pollution impacts ................................................................................................................................. 10
The Network Proposal ...................................................................................................................................................................... 11
Impact on state waters ................................................................................................................................................................. 11
Estimate of displaced fishing effort .............................................................................................................................................. 11
Activities allowed within reserves................................................................................................................................................. 11
Review of individual reserves........................................................................................................................................................ 17
Recommendations and Conclusions ................................................................................................................................................. 22
Recommendations: ....................................................................................................................................................................... 22
Conclusions: .................................................................................................................................................................................. 23
Contact .............................................................................................................................................................................................. 24
References ........................................................................................................................................................................................ 25
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EXECUTIVE SUMMARY
The
Boating and Fishing Council of Australia
has reviewed The Marine Bioregional Plan for the South-west
Marine Region (draft) and The Proposal for the South-west Commonwealth Marine Reserves Network. In general, we are broadly
supportive of the plan and the reserve network and believe that this is a positive step towards promoting environmental
stewardship in the marine environment of the South-west Region.
We believe there are some points that require further discussion in order to improve the plan and we trust that our submission
will open the pathway to further dialogue between the recreational fishing and boating industry and the Australian Government.
These are detailed below:
1.
We do not believe that it is the responsibility of the state/territory fisheries management agencies to deal with impacts
caused by the displacement of fishing activities as a result of Commonwealth MPA declarations and zoning and
recommend that this expectation is removed from the Fisheries Adjustment Policy.
2.
We recommend that independent researchers must be used to conduct the social and economic analysis mentioned in
the Fisheries Adjustment Policy and that such analysis must include the recreational fishing and boating sectors.
3.
We recommend that any reference to a presumed growth in recreational fishing is reconsidered and reference is made
to the decreasing recreational fishing effort as demonstrated in the latest reports on recreational fishing in the Southwest Marine Region.
4.
The rationale for considering fishing (extraction of living resources) a pressure of potential concern is revised in light of
progress made in the last decade towards Ecosystem Based Fisheries Management. A broader list of references must
be included (i.e. Hall and Wise 2011; Penn and Fletcher 2010) that reflects the sustainable fisheries management
practices currently in place in these jurisdictions.
5.
We strongly recommend that additional explanatory notes or definitions are provided in the Plan that clearly describe
the variety of fishing activities that occur and their associated risks. In particular, definitions of the pressures posed by
recreational and commercial fishing activities must clearly distinguish between the two different sectors and different
fishing activities. A definition for charter fishing should also be included that clearly identifies the tourism aspect of
charter fishing operations.
6.
That tenuous claims that managed recreational fishing has major ecological impacts on seabird and turtle populations
must be removed.
7.
We recommend that either evidence is provided to support the claim of increasing recreational and commercial
boating in the South west Region or else the statement is deleted.
8.
Any management plan for the South-west Marine Region must consider the management and mitigation of
anthropogenic sources of habitat modification and pollution and develop, in consultation with the State authorities, a
“ridge to reef” action plan to address these concerns.
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9.
This Marine Bioregional Planning process considers what incremental impacts these and their complementary state
marine parks will have on users of the marine environment, particularly in terms of displaced commercial and
recreational fishing effort.
10. We recommend that Section 3 of the Network Proposal on integrating social and economic considerations is greatly
expanded commensurate with the importance of this aspect of marine park planning. Further detail needs to be
provided about how impacts will be assessed and what adjustment measures will be offered to affected individuals and
communities.
11. We strongly recommend that the Australian Government precedent for allowing sustainably managed recreational
fishing within Marine National Park (IUCN II) Zones is continued in the South-west Marine Region subject to criteria
developed in conjunction with State Government Fisheries departments and the recreational fishing industry.
12. For each proposed reserve, sustainably managed recreational fishing should be allowed to occur within the Marine
National Park (IUCN Category II) Zones consistent with the current management arrangements in place in IUCN
Category II Commonwealth Marine Reserves in other Marine Regions.
13. The requirement for charter fishing activities to be subject to approval in general use and special purpose zones is
reviewed and consideration is given to recognising existing license or permit arrangements under state fisheries
legislation for these circumstances.
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PURPOSE SCOPE AND OBJECTIVE
Purpose
The purpose of this submission is to formally respond to The Marine Bioregional Plan for the South-west Marine Region (draft) the “Plan” and to formally respond to The Proposal for the South-west Commonwealth Marine Reserves Network - the “Network
Proposal”.
Scope
The Boating and Fishing Council of Australia is an industry-end user alliance of the recreational boating and fishing sectors. Our
constituents include over 5 million recreational fishers (ABS 2003) and boaters and thousands of staff (approximately 90,000 –
ABS 2003) employed in the boating retail and manufacturing industries; outboard engine and associated industries; fishing
tackle and associated trades and the charter and guided fishing industries. Our combined contribution to the Australian
economy equates to several billions of dollars per annum including an estimated $200 million from international fishing tourists
(ABS 2003) and approximately $2 billion in spending by Australian recreational fishers (AIMS 2010). The recreational boating
industry in Australia generates about $13.4 billion in spending which includes industry turnover and additional tourism spending.
The sector generates direct industry revenue of $7.8b nationally including $1,268m in export sales and contributes $4.1b to the
economy supporting over 74,196 jobs (EMDA 2007). Approximately 1.6 million Australian individuals hold marine boating
licenses (7% of the population) and 4% own a registered recreational boat (804,268 vessels) (EMDA 2007). Some jurisdictions
such as the Northern Territory do not require registration of recreational boats and some classes of boat are exempt from
registration. In 2005, Dominion Consulting estimated that the value of retail sales in the tackle and bait industry in 2003-04 was
around $665 million (Dominion Consulting 2005 in ABARE-BRS 2010). With specific reference to Western Australia, EMDA (2007)
estimated that the economic value of recreational fishing using a boat was $192.9m which excluded the purchase of trailers and
boats.
The scope of our submission is limited to the recreational boating and fishing sector and we make no comment on the suitability
of the Plan or the Network for other users of the marine environment including commercial fishing, marine tourism and the oil
and gas industry.
Objective
The objective of this submission is to highlight issues of concern to our sector in both the Plan and the Network Proposal and to
comment more broadly on the Marine Bioregional Planning process including elements of the Fisheries Adjustment Policy – the
“Policy”. We intend to provide recommendations on how the Plan and the Network Proposal could be improved and further
recommendations on improvements to the Fisheries Adjustment Policy.
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GENERAL COMMENTS
The rationale and policy behind the Marine Bioregional Planning process has been explained in a number of different and
sometimes contradictory ways. Most explanations relate to Australia’s obligations under international agreements and treaties.
Diggles (2011) in his recent submission to the Parliamentary Inquiry into the Environmental Protection and Biodiversity
Amendment (Bioregional Plans) Bill 2011 reviews the nature of these obligations and suggests that Australia is likely to have
already met its international obligations under the Jakarta Mandate (1992) of the Convention on Biological Diversity. Australia
also made a commitment at the World Summit on Sustainable Development (2002) to establish a representative network of
marine reserves by 2012. The fact that most other signatories have failed to come close to achieving that goal has led to the
recent revision of the deadline to 2020.
For too long, the Australian Government has allowed the issue of marine conservation to become politicised and factional
resulting in significant community rifts. In particular, environmental groups have conducted an aggressive campaign based on
misleading statements, misrepresentation of data and deliberate purchasing of pro marine sanctuary science has resulted in
much angst and confusion within Australian communities.
These well funded media campaigns have not been countered by any responsible government commentary or an attempt to
focus the community on the true aims and objectives of the Marine Bioregional Planning process.
Concerns from our sector that well funded and politically connected anti-fishing lobby groups are influencing government policy
were strengthened with the declaration of the Coral Sea Conservation Zone by former environment minister, the Honourable
Peter Garrett. We are still extremely concerned about this apparently unnecessary and politically motivated declaration which
we seriously believe undermines the integrity of the Marine Bioregional Planning process.
With the onset of a Carbon Trading Scheme, increased fuel costs and a range of other changes that will inflict uncertain impacts
on our industries and our communities, it is vital that this Plan for the South West region fully considers the impacts on all users
and consumers. The recreational boating and fishing sector is fully committed to the principles of Ecologically Sustainable
Development provided that all principles are considered fairly and equitably. This means that the economic and social
consequences of conservation actions are considered alongside the environmental impacts of development.
We also believe that any decisions relating to management of activities within Australia’s marine environment must be based on
the best available science and each proposed action must be scientifically defensible. In our opinion, the Precautionary Principle
has been misused with respect to the impact of recreational fishing on marine biodiversity and conservation values and led to
misdirection of resources and attention away from the most damaging impacts on marine biodiversity which include land based
anthropogenic activities and practices.
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FISHERIES ADJUSTMENT POLICY
The Fisheries Adjustment Policy presented by the Australian Government is almost entirely focused on Commonwealth
commercial fisheries under the management of the Australian Fisheries Management Authority. The policy considers fishing to
be a private benefit activity, and also fails to separate recreational from commercial fishing. Both of which are significant
misrepresentations. Recreational fishing can be defined as activities that create personal enjoyment and recreation from fishing
and includes the supporting industries such as fishing tour and charter operators, fishing guides, boating and outboard engine
distributors, fishing tackle retailers, manufacturers and distributors, the fishing media and a host of other allied activities.
Recreational fishing is thus very much a public benefit activity that provides social and health benefits for a great number of
Australians from all backgrounds and walks of life. Recreational fishers are not dependent on their catch for their livelihood and
derive no economic benefit from their activities. Instead, the more than 5 million Australians that go recreational fishing each
year provide significant economic input into regional economies and support local businesses and enterprises, particularly in
rural and regional areas.
The policy also states that there is an expectation that declaration and zoning of MPAs will require the responsible fisheries
management agency to make revisions to its own fisheries management regimes. Recreational fishing and charter fishing
activities are managed under state and territory legislation which extends to activities in Commonwealth Waters. Management
arrangements for these sectors are a result of extensive consultation and engagement between the relevant fisheries
management agency and the sector. We do not believe that it is the responsibility of the state/territory fisheries management
agencies to deal with impacts caused by the displacement of fishing activities as a result of Commonwealth MPA declarations
and zoning and recommend that this expectation is removed from the Fisheries Adjustment Policy.
Current fisheries management arrangements in the jurisdictions impacted by the Marine Bioregional Planning process are based
on the principles of Ecologically Sustainable Development and are committed to delivering Ecosystem Based Fisheries
Management outcomes. This is attested to by the ongoing assessment and approval of fisheries under the Environment
Protection and Biodiversity Conservation Act 1999.
It is inconceivable and inconsistent that the same Act will now require additional fisheries management adjustments to occur
when existing arrangements are considered sustainable.
The Fisheries Adjustment Policy is also vague and lacks sufficient detail to determine what components of the recreational
boating and fishing sector will be considered for assistance. We are sceptical about how public good benefits relating to
biodiversity conservation will adequately compensate for the direct economic losses resulting from loss of access to existing
traditional and potential future recreational fishing locations.
The Policy is unclear relating to the circumstances under which local communities may be considered for assistance or what
exactly constitutes a “local community”. It is also unclear whether charter fishing would be considered as a commercial fishing
activity and how the level of assistance will be determined.
We have grave concerns that this Fisheries Adjustment Policy fails to provide anywhere near the level of detail needed and
agreed to by the Displaced Activity Stakeholder Advisory Group. We also draw your attention to the considerable body of work
that has already been completed relating to social assessment of Australian fisheries including the Social Assessment Handbook
(Schirmer and Casey 2005) and the analysis of ESD and Fisheries by Professor Tor Hundloe (Hundloe 2010).
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We recommend that independent researchers must be used to conduct the social and economic analysis mentioned in the
Fisheries Adjustment Policy and that such analysis must include the recreational fishing and boating sectors.
THE PLAN
In general terms, we have no issue with the goals of the Plan and we believe that consideration has been given to recreational
fishing activities that occur within the South-west Marine Region. We are strongly supportive of Strategies A, C, D, E and G and
are especially committed to developing partnerships between our industries, the Australian Government and other groups with
an interest in conservation of the marine environment. We would like the opportunity to discuss the Recreational Fishing
1
Industry Development Strategy that has recently been released by the Australian Government and identify synergies and
opportunities to progress aspects of that strategy with reference to marine conservation.
While we are supportive of the South-west Marine Region Plan, we do, however, have concerns about several statements and
discussions within the Plan that relate to recreational fishing and which we feel can be improved.
DISTINGUISHING RECREATIONAL FROM COMMERCIAL FISHING
Throughout the Plan, reference is made to fishing pressure (in particular in Table 3.1 and Table 3.2) without citing whether it is
commercial or recreational fishing or the detail of which particular fishing gear or fishery is giving rise to the concern in the
pressure rating. It is then extremely difficult to address the concerns raised which for the recreational fishery may be of lesser or
no concern. For example, in Table 3.1 Item 11 Commonwealth marine environment surrounding the Houtman Abrolhos Islands,
there is a reference to Tables S1.12 and S1.13 of Schedule 1 in relation to pressures that are either not well understood or
expected to increase. The same pressure rating relates to Item 15 Commonwealth marine environment surrounding the
Recherche Archipelargo and Item 16 Kangaroo Island Pool, canyons and adjacent shelf break, and the Eyre Peninsula upwellings.
Some of these concerns relate to climate or environmental change effects which we accept are not yet well understood,
however we have major concerns about presumed fishing related pressures that are both ill defined and unsubstantiated.
Using the definition of pressure categories and ranking criteria presented on page 13 in the Overview of Marine Bioregional
Plans (DSEWPaC, 2011), we believe that recreational fishing is best defined as a pressure of less concern.
It is our belief that there is compelling evidence that:
•
... there are reasonable grounds to expect that the impacts are unlikely to be substantial,
AND
• ... there are reasonable grounds to expect that current management measures in place are effective in minimising or
mitigating the impact.
In the face of existing evidence of the management measures currently in place to manage recreational fishing, it is simply not
possible to accept that recreational fishing fits into the category of either of concern or of potential concern.
1
http://www.daff.gov.au/fisheries/recreational/rfids
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EXPANSION OF RECREATIONAL FISHING EFFORT
Table 3.2: Environmental pressures of regional priority for the South-west Marine Region considers Extraction of living resources
as a pressure of regional priority (page 39) and states that; “recreational fishing in the region is believed to have increased
substantially and contributed to the overfishing of important demersal finfish off the west coast”. No reference is provided for
this ambiguous and misleading statement which does not reflect the current status of recreational fishing for demersal finfish. In
July 2009, the Western Australian government took steps to ensure the long term sustainability of demersal fish stocks such as
Snapper (Pagrus auratus), West Australian Dhufish (Glaucosoma hebraicum) and Baldchin Groper (Choerodon rubescens).
The steps included the adoption in October 2009 of a boat fishing license for recreational fishers targeting these species. By
October 2010, recreational fishing effort had decreased by almost 50% since the last survey of the West Coast Bioregion in 2005,
thus fulfilling the management objective (Honourable Norman Moore, 2010). The boat license, a two month closure and
conservative bag and size limits remain in place for the recreational demersal fishery.
Similarly, the latest recreational fishing survey for South Australia (Jones 2009) also demonstrated a decline in the number of
recreational fishers in that State between 2000/01 and 2007/08 (23.3% to 16.2% of the population) and in fishing effort (42%
decrease) and catch (46% decrease). Faced with this compelling evidence of a decline in recreational fishing participation, effort
and catch, we recommend that any reference to a presumed growth in recreational fishing is reconsidered and reference is
made to the decreasing recreational fishing effort as demonstrated in the latest reports on recreational fishing in the Southwest Marine Region.
ECOSYSTEM IMPACTS OF FISHING
In Schedule 1, Table S1.13: Pressures of potential concern to key ecological features of the South-west Marine Region considers
Extraction of living resources as a potential concern (Page 89). The rationale offered contains some statements that require
further consideration.
In the first instance, it is stated that “understanding of ecosystem effects of fishing is very limited”. We strongly disagree with
this statement and believe that in contrast to a decade ago when Ecosystem Based Fisheries Management was a novel concept,
ESBFM has progressed significantly in Australia and internationally. With particular reference to Western Australia waters and
fisheries, the recent Fisheries Research and Development Corporation/ Department of Fisheries, Western Australia funded study
(FRDC 2005/063) provides a comprehensive review of the impacts of fishing on community composition of marine ecosystems in
each bioregion of WA (Hall and Wise 2011). This paper concludes that rather than fishing having the assumed devastating
impact suggested in Table S1.13 (implied through the indiscriminate use of the term ‘overfished’ without an explanation of what
the term means), analysis of over 30 years’ of fisheries data has demonstrated that there has been no reduction in mean trophic
level or mean maximum length in finfish catches which are both classic examples of fisheries – ecosystem interactions (fishing
down the food web).
Furthermore, the paper by Hall and Wise suggests that both the trophic level and mean length indices are possibly being
maintained through spatial expansion of fishing and/or changes in targeting. This poses an interesting challenge where spatial
expansion is restricted (for example through the establishment of marine protected areas) and it may no longer be possible to
maintain ecosystem indices at current levels. In such a scenario, marine reserves can actually negatively impact the very
communities that they claim to protect. With specific respect to WA waters, Penn and Fletcher (2010) reviewed the
effectiveness of marine sanctuary areas compared to other methods of managing fish stocks and biodiversity and found that a
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significant percentage of waters and their associated ecosystems were currently protected in WA through a range of fisheries
management measures.
Advances in linking fishing impacts and ecosystems have also continued at a national level with a National ESD framework for
fisheries and an FRDC ESD Reporting and Assessment subprogram supporting the assessment of all fisheries that are required to
be assessed under the EPBC Act 1999. A Natural Resource Management Standing Committee (NRMSC) endorsed initiative to
deal with cross-fishery issues relating to ESD has also been initiated.
It is therefore, not appropriate to state that “understanding of ecosystem effects of fishing is very limited”. While standard
techniques require further development, significant progress on addressing the ecosystem impacts of fishing has been made and
it is our recommendation that the rationale for considering fishing (extraction of living resources) a pressure of potential
concern is revised in light of progress made in the last decade towards Ecosystem Based Fisheries Management. A broader list
of references must be included (i.e. Hall and Wise 2011; Penn and Fletcher 2010) that reflects the sustainable fisheries
management practices currently in place in these jurisdictions.
IMPACTS OF FISHING ON PROTECTED SPECIES
Figure S1.1: Assessment of the level of concern associated with the effects of pressures on selected protected species in the
South-west marine region of Schedule 1 lists Extraction of living resources as having an impact of potential concern on
Australian sea lion. For the same species, Bycatch is considered as an impact of concern.
Quite clearly, these concerns relate to commercial fishing and not recreational fishing but there are no explanatory notes to
assist readers. Uninformed respondents might believe that all forms of fishing share the same level of concern. In the same
figure, Southern Bluefin Tuna are the only bony fish species where extraction of living resources is considered as an impact of
concern. While the concern has some credibility, conservation of Bluefin Tuna is an international issue which will require an
international response. Well managed recreational fishing is unlikely to be of any concern to global stocks of Southern Bluefin
Tuna. Again, there is a need to include more detail in order to better define the levels of concern relating to specific fisheries
and/or aspects of those fisheries.
We strongly recommend that additional explanatory notes or definitions are provided in the Plan that clearly describe the
variety of fishing activities that occur and their associated risks. In particular, definitions of the pressures posed by
recreational and commercial fishing activities must clearly distinguish between the two different sectors and different fishing
activities. A definition for charter fishing should also be included that clearly identifies the tourism aspect of charter fishing
operations.
Table S1.6: Pressures of potential concern to selected seabirds in the South-west Marine Region of Schedule 1 (page 69) suggests
that declines in the number of predatory fish may have implications for seabird prey availability by diminishing the ability of
feeding schools of tuna and other pelagic fish to concentrate baitfish near the surface. The rationale then goes on to suggest
that it is not possible to separate the effect of tuna fishing from other oceanic and climatic effects in the eastern Indian Ocean.
Given the lack of evidence to suggest that there are any declines in abundance of large predatory species, we find this attempt
to link extraction of living resources as a potential concern to seabirds is weak at best and most likely of no concern.
In contrast, there are real threats that are not addressed by the MPA, such as introduction of exotic diseases, including the
exotic herpesvirus that resulted in severe mortality of up to 60% of the pilchard stocks in the SW Marine Region in both 1995
and 1998 (Whittington et al. 2008). A dieoff which had substantial negative flow on effects to the ecosystem, including penguins
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and other seabird populations (Dann et al. 2000, Bunce and Norman 2000). We recommend that the rationale for considering
fishing as an impact of potential concern is revised to remove reference to the tenuous claim that fishing for pelagic species
can impact seabirds.
In the same table (page 70), Collision with vessels is listed as of potential concern for the Little Penguin. The rationale makes
mention of ‘rapidly increasing numbers of recreational craft’ near Perth. Again, it would be useful to cite a reference for this
claim or provide further information about what sorts of vessels are likely to impact penguin colonies in Commonwealth Waters.
Table S1.7: Pressures of potential concern to selected marine turtle species in the South-west Marine Region (page73) cites the
same concern for Collision with vessels for three species of marine turtle. Again, claims about increasing numbers of
commercial and recreational vessels is used as rationale for the concern but no reference is provided with data to support these
claims. We recommend that either evidence is provided to support the claim of increasing recreational and commercial
boating activity in the South-west Marine Region or else the statement is deleted.
HABITAT MODIFICATION AND POLLUTION IMPACTS
We are pleased to note that habitat modification through either natural or anthropogenic effects has been considered as an
impact together with those from chemical and nutrient pollution. We do, however, make the point that declaration of marine
reserves and subsequent zoning has little impact on land-based activities and their impacts on marine ecosystems. The
Worldfish Centre published a “lessons learned” paper on MPA implementation based on 20 years experience developing MPAs
globally. They noted that current MPA management practice does not place sufficient emphasis on threats that arise from
outside the management area, and that any approach to marine biodiversity conservation MUST account for these impacts
(Worldfish Centre, 2008). Indeed, they recommend full integration of management of issues such as sedimentation and
sediment resuspension into coastal marine protection plans, otherwise further declines in resources will continue to occur. They
consider that MPAs should be part of an integrated “ridge to reef” management plan that includes wise land use practices and
watershed management (Worldfish Centre, 2008).
We also believe that greater emphasis and resources should be placed on addressing these important landbased issues in a
proactive and co-management focused way. There is a popular misconception amongst certain sectors of the community that a
network of marine reserves will somehow mitigate the effect of these impacts as well as the uncertain impacts of climate and
environmental change. This is simply not the case and focusing on marine protected areas may well divert attention away from
the more significant and widespread impacts of habitat modification and pollution.
We, therefore recommend that any management plan for the South-west Marine Region must consider the management and
mitigation of anthropogenic sources of habitat modification and pollution and develop, in consultation with the State
authorities, a “ridge to reef” action plan to address these concerns.
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THE NETWORK PROPOSAL
IMPACT ON STATE WATERS
The draft network proposal contains frequent mention that this marine bioregional planning process pertains to Commonwealth
Waters and that the proposal will have no impact on state waters. We believe that this statement is misleading since our
experience in marine protected area planning in other jurisdictions has demonstrated a strong correlation between the location
of Commonwealth Marine Parks and complementary marine parks within state waters. Clear examples exist in the Great Barrier
Reef region where rezoning of the Great Barrier Reef Marine Park (a Commonwealth Marine Park) was closely followed by
similar zoning within state waters declared under Queensland legislation. It is therefore vital, that this Marine Bioregional
Planning process considers what incremental impacts these and their complementary state marine parks will have on users of
the marine environment, particularly in terms of displaced commercial and recreational fishing effort.
ESTIMATE OF DISPLACED FISHING EFFORT
The Network Proposal suggests that only 1 -2 percent of the gross value of production of the region’s fisheries will be displaced.
We believe that it is irresponsible to suggest such a low figure without providing details of the modelling used. There is no
indication of whether this pertains only to Commonwealth commercial fisheries or whether it extends to state commercial and
charter fishing operators. It is also unclear whether the impact on recreational fishers has been considered at all. In our
experience, a priori estimates of the impacts of marine parks are gross underestimates that fail to consider the full socioeconomic costs (McPhee 2011). Indeed, this is entirely consistent with the Federal Government taking a position that oversells
theoretical benefits of MPAs while de-emphasising the real costs, a process that is condemned by global authorities in the field
of MPA planning and implementation (Worldfish Centre, 2008). With scant detail in the Fisheries Adjustment Policy, we are
extremely concerned about how displaced effort will be assessed and adjustment determined. We recommend that Section 3 of
the Network Proposal on integrating social and economic considerations is greatly expanded commensurate with the
importance of this aspect of marine park planning. Further detail needs to be provided about how impacts will be assessed
and what adjustment measures will be offered to affected individuals and communities.
ACTIVITIES ALLOWED WITHIN RESERVES
Section 5 of the Network proposal considers the types of activities allowed within each IUCN categorised zone of the reserve
network. With reference to highly protected or ‘no-take’ Marine National Park Zones, we note that an IUCN Category II has been
adopted. We note that the definition used with reference to the South-west Commonwealth Marine Reserve Network is that
“These zones exclude all commercial activities and extractive recreational activities (except passage of vessels and nonextractive tourism).” We believe that such a definition is not consistent with the Australian IUCN Reserve Management
Principles for Commonwealth MPAs (Schedule 8 of the Environment Protection and Biodiversity Conservation (EPBC) Regulation
2000) and that sustainably managed recreational fishing should be allowed to continue within all Marine National Park (IUCN II)
Zones in the South-west Marine Reserve Network.
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2
The official IUCN definition of Category II is: “Category II protected areas are large natural or near natural areas set aside to
protect large-scale ecological processes, along with the complement of species and ecosystems characteristic of the area,
which also provide a foundation for environmentally and culturally compatible spiritual, scientific, educational, recreational
and visitor opportunities.”
Similarly, the Draft Australian Handbook for Application of IUCN Protected Area Management Categories (WCPA 2000) clearly
classifies IUCN Category II as follows:
Category II. National Park: Protected area managed mainly for ecosystem protection and recreation
Definition
Natural area of land and/or sea, designated to (a) protect the ecological integrity of one or more ecosystems for present and
future generations, (b) exclude exploitation or occupation inimical to the purposes of designation of the area and (c) provide a
foundation for spiritual, scientific, educational, recreational and visitor opportunities, all of which must be environmentally and
culturally compatible.
Objectives of management
To protect natural and scenic areas of national and international significance for spiritual, scientific, educational, recreational or
tourist purposes.
Based on the above definitions, we can find no reason why sustainably managed recreational fishing practices cannot occur
within Marine National Park Zones. Furthermore, we argue that sustainably managed recreational fishing experiences are
completely complementary with the other objectives of Category II, namely:
•
To manage visitor use for inspirational, educational, cultural and recreational purposes at a level which will not cause
significant biological or ecological degradation to the natural resources;
•
To take into account the needs of indigenous people and local communities, including subsistence resource use, in so
far as these will not adversely affect the primary management objective;
•
To contribute to local economies through tourism.
Australian IUCN Reserve Management Principles for Commonwealth MPAs (Schedule 8 of the EPBC Regulations 2000) considers
that National Park (IUCN II) zones should be managed according to the following principles:
3.01 The reserve or zone should be protected and managed to preserve its natural condition according to the following
principles.
3.02 Natural and scenic areas of national and international significance should be protected for spiritual, scientific, educational,
recreational or tourist purposes.
2
http://www.iucn.org/about/work/programmes/pa/pa_products/wcpa_categories/pa_categoryii/
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3.03 Representative examples of physiographic regions, biotic communities, genetic resources, and native species should be
perpetuated in as natural a state as possible to provide ecological stability and diversity.
3.04 Visitor use should be managed for inspirational, educational, cultural and recreational purposes at a level that will maintain
the reserve or zone in a natural or near natural state.
3.05 Management should seek to ensure that exploitation or occupation inconsistent with these principles does not occur.
3.06 Respect should be maintained for the ecological, geomorphologic, sacred and aesthetic attributes for which the reserve or
zone was assigned to this category.
3.07 The needs of indigenous people should be taken into account, including subsistence resource use, to the extent that they
do not conflict with these principles.
3.08 The aspirations of traditional owners of land within the reserve or zone, their continuing land management practices, the
protection and maintenance of cultural heritage and the benefit the traditional owners derive from enterprises, established in
the reserve or zone, consistent with these principles should be recognised and taken into account.
In fact, the Australian Government precedent for allowing recreational and charter fishing to occur in IUCN Category II Zones has
3
already been set for Commonwealth Marine Parks in the South-east Marine Region .
Recreational Use Zone (IUCN II) - This zone allows for recreational and charter fishing if carried out in accordance with the
relevant State fishing arrangements. It prohibits commercial fishing and mining activities.
In the South-east, consideration was also given to allow certain types of recreational fishing in IUCN Category Ia sanctuary zones:
Benthic Sanctuary Zone (IUCN Ia) - Some commercial and recreational fishing is permitted. However no fishing or other
extractive use in the area from 500 metres below sea level to 100 metres beneath the seabed is allowed.
3
http://www.environment.gov.au/coasts/mpa/southeast/activity.html
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Table 1. Activity management in the South-east Marine Region (extracted from DSEWPac website, 14/6/2011)
Table continued over page
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Recreational fishing is also currently allowed in IUCN II Zones within Commonwealth Marine Reserves in the North-west Marine
4
Region including Ningaloo Marine Park (Commonwealth Waters) and Ashmore Reef National Nature Reserve (subject to the
5
conditions of the approval) and in the East Marine Region in the IUCN II Zone within the Elizabeth and Middleton Reefs Marine
6
National Nature Reserve (subject to issue of a permit) . In the Solitary Islands Marine Reserve (Commonwealth Waters),
7
recreational fishing is only excluded from the small Sanctuary Zone (IUCN 1a) around Pimpernel Rock .
Given these numerous precedents, we therefore see no reason why recreational fishing and charter fishing should be
completely excluded from IUCN II zones in the South West Region. Why would recreational fishing activities pose a greater risk
to marine biodiversity in the South-west Marine Region compared to other IUCN II zones in other regions within the Australian
jurisdiction? In fact, given that most of the issues that give rise to the potential concern relating to over extraction of living
resources relate to some commercial fishing practices, it is our belief that sustainably managed recreational fishing activities,
either private or as part of charter fishing tours, and carried out in accordance with existing state recreational fishing regulations
should be allowed to continue in Marine National Park (IUCN II) Zones.
4
5
6
7
http://www.environment.gov.au/coasts/mpa/ningaloo/activities.html
http://www.environment.gov.au/coasts/mpa/ashmore/activities.html
http://www.environment.gov.au/coasts/mpa/elizabeth/activities.html
http://www.environment.gov.au/coasts/mpa/solitary/activities.html
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Indeed, there are several recent international precedents where recreational fishing has been allowed to continue in large
marine protected areas, including the Marianas Islands and Pacific Remote Islands National Marine Monuments (US
Jurisdiction), and the Chagos Marine Protected Area (British Indian Ocean Territory) (see Diggles 2011 for details). Furthermore,
Yellowstone National Park in the USA was the world’s first national park, established in 1872. Today Yellowstone National Park
8
meets IUCN II criteria , but recreational fishing is permitted in the park and indeed has always been central to management of
that park for over 140 years (Diggles 2011).
Notwithstanding all of these precedents both within Australia and overseas, even if the Federal Government simply “has to
have” a complete non-extractive position relating to IUCN II zones in the South-west Marine Region, this still does not exclude
suitably managed non-extractive recreational fishing practices, such as catch and release fishing, and “no take away” wilderness
fishing. Furthermore we believe that there is great potential to involve recreational fishers in research and monitoring activities
within federally managed marine national parks, with fishers and scientists working together towards positive conservation
outcomes. An example of this is the existence of recreational research tagging programs within all states of Australia with strong
collaboration with national and international conservation programs.
The value of involving recreational fishers in marine conservation programs is internationally recognised and a prominent
9
example is the tagging of Atlantic Bluefin Tuna in the Mediterranean by recreational fishers working with WWF .
We strongly recommend that the Australian Government precedent for allowing sustainably managed recreational fishing
within Marine National Park (IUCN II) Zones is continued in the South west Region subject to criteria developed in conjunction
with State Government Fisheries departments and the recreational fishing industry.
Table 5.1 Overview of proposed zoning scheme for the South-west Commonwealth Marine Reserve Network in the Network
proposal (pg 9) provides an overview of the types of activities allowed within each proposed zone. We note that charter fishing
is proposed to be excluded from Marine National Park (IUCN II) Zones in contrast to other tourism activities which will be
allowed to continue in these areas. In light of the points raised above regarding inconsistencies between previous Federal
Government decisions re: fishing tourism in IUCN II zones, we believe that there is a place for recreational fishing activities
subject to agreed criteria within IUCN II Marine National Park Zones and that fishing tour operators should be given the same
opportunities as other tour operators.
We also note that fishing tour operators fishing within Multiple Use Zones and Special Purpose Zones will be subject to
assessment and approval of their activities: “Approval will be required for these activities (e.g. registration, general approval
or individual permit) in multiple use and special purpose zones.” We believe that such a measure is unnecessarily duplicative
considering that these operators are already licensed or subject to permit conditions under state legislation. We are concerned
that should a registration or permit system be required by the Commonwealth for fishing charter operations within general use
and special purpose zones, this will create an unacceptable regulatory burden on individual charter operators. We also consider
it to be patently unfair that no similar requirement is applied to other tourism operators except in Marine National Park Zones
(where permits could also be granted to fishing charter operators if certain recreational fishing activities were allowed as
discussed above).
8
9
http://www.unep-wcmc.org/protected_areas/categories/eng/ex-ii.pdf
http://wwf.panda.org/what_we_do/footprint/smart_fishing/target_fisheries/bluefin_tuna/tracking_the_giants/
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The nature of the charter industry is such that many business models combine fishing with whale watching, bird watching and
snorkelling activities. It simply does not make sense to develop an approvals system for one component of marine tourism
without regard for a whole-of-industry approach.
We recommend that the requirement for charter fishing activities to be subject to approval in General Use and Special
Purpose Zones is reviewed and consideration is given to recognising existing license or permit arrangements under state
fisheries legislation for these circumstances.
REVIEW OF INDIVIDUAL RESERVES
Assessing the impact of the proposed reserves and associated zones on recreational fishing is difficult. It is complicated by a lack
of readily accessible information about recreational fishing activities currently occurring within Commonwealth Waters and the
level and location of activities into the future. Equally difficult to determine is the impact from displaced commercial and
recreational fishing activity which must be accounted for when considering the implications of a network of large marine
reserves. For recreational fishing, with its diversity of drivers, motivations and expectations, assessing the impact requires expert
knowledge and advice. McPhee (2011) explains that the recreational specialisation of fishers is seldom considered in assessment
of the impacts of marine reserves on recreational fishing participants. This lack of understanding is apparent in discussion of the
activities within each reserve presented in the Network Proposal. Frequent mention is made that the majority of recreational
fishing activity occurs within state waters. We do not completely disagree with this assumption but argue that simply because
fewer fishers venture into Commonwealth Waters does not mean that access to these locations is any less important. In a recent
report to DSEWPaC prepared by Recfish Australia, the importance of ongoing access to Commonwealth Waters was made very
clear (Recfish Australia, 2010).
This same report also attempted to map out core areas of importance to recreational fishers with respect to the Areas for
Further Assessment released by DSEWPaC in 2010. The report stressed that these were the minimum areas that recreational
fishers currently accessed and that more detailed information would be required to determine the impact of individual reserves
once the boundaries were determined.
Abrolhos Commonwealth Marine Reserve
The proposed reserve boundaries and zoning seems reasonable, our only recommendation is that sustainably managed
recreational fishing should be allowed to occur within the Marine National Park (IUCN Category II) Zone consistent with the
current management arrangements in place in IUCN Category II Commonwealth Marine Reserves in other regions.
Alternatively, if the Federal Government “has to have” a complete non-extractive position relating to IUCN II zones in the South
West Marine Region, this still does not exclude suitably managed non-extractive recreational fishing practices, such as catch and
release fishing, and “no take away” wilderness fishing.
Jurien Commonwealth Marine Reserve
The proposed reserve boundaries and zoning seems reasonable.
Perth Canyon Commonwealth Marine Reserve
The proposed reserve boundaries and zoning seems reasonable.
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South-west Corner Commonwealth Marine Reserve
The South-west Corner reserve is undoubtedly the largest of the proposed reserves with the greatest percentage of Marine
National Park Zone (77.3%). As such, the reserve has the greatest potential impact on recreational fishing activities within the
South-west Marine Region. The Recfish Australia report identified a minimum core area of importance to recreational fishers
within the South-west Corner. Reviewing this area in relation to the proposed marine reserve boundary and zoning, it is
apparent that recreational fishers will be directly impacted by the proposal (Figure 1).
As with our previous comments, our first recommendation is that suitably managed recreational fishing is allowed to occur
within the Marine National Park (IUCN Category II) Zone consistent with the current management arrangements in place in
other IUCN Category II Commonwealth Marine Reserves. If recreational fishing were allowed to continue within the Marine
National Park Zone, we would fully support the proposed zoning. If the management objective is protection of benthic flora and
fauna, including demersal fishes, this should not exclude recreational fishing for pelagic fishes, as per the precedents set for
benthic sanctuary zones in the South East Region (Table1). Alternatively, if the Federal Government “has to have” a complete
non-extractive position relating to IUCN II zones in the South West Marine Region, this still does not exclude suitably managed
non-extractive recreational fishing practices, such as catch and release fishing for pelagic fishes and “no take away” wilderness
fishing.
On the other hand, if DSEWPaC continues with its apparent intention to redefine the purpose of IUCN Category II Zones in
Australia and reject the Australian IUCN reserve management principles (Schedule 8 of the EPBC Regulations 2000) by excluding
all recreational fishing activities from IUCN II Zones, then we offer the following comments. The three isolated Marine National
Park Zones at: Margaret River (34˚S – 34˚ 12’S); near Walpole (115˚ 42’E-115˚54’E) and near Esperance (120˚ 42’E - 121˚ 03’E) lie
within the core area of importance to recreational fishers and should be reconsidered. The location and design of these zones
contradicts the following principles for the establishment of the National Representative System of Marine Protected Areas in
Commonwealth waters:
1. MPAs will be located taking into account the occurrence and location of existing spatial management arrangements (e.g.
existing protected areas and sectoral measures) that contribute to the goals. These zones fail to consider the role of Western
Australia fisheries management measures in minimising the impact of recreational fishing on several key species.
2. The goals should be met with the least number of separate MPAs (i.e. a smaller number of larger MPAs rather than many
small MPAs) to maximise conservation outcomes. Clearly this is not being achieved through these small areas and their
effectiveness is questionable given the extensive size of the Marine National Park Zone further offshore.
3. The capacity of an MPA to mitigate identified risks to conservation values.
4. The occurrence of spatially defined habitats for and/or aggregations of threatened and/or migratory species.
5. The occurrence of ecologically important pelagic features which have a consistent and definable spatial distribution.
Since recreational fishing has not been demonstrated to be an activity of concern and with its flagging as of potential concern in
doubt, rezoning these areas or selecting alternative sites for these zones should not prevent the zones from achieving the
principles above.
At the same time, rezoning or changing the location of these zones would allow compliance with the following principle:
9. Socio-economic costs should be minimised.
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Figure 1. South-west Corner and Eastern Recherche proposed Commonwealth marine reserve zoning with core recreational fishing areas identified.
Eastern Recherche Commonwealth Marine Reserve
The Recfish Australia report (Recfish Australia 2010) identified a minimum core area of importance to recreational fishers within
the Eastern Recherche area. Reviewing this area in relation to the proposed marine reserve boundary and zoning, it is apparent
that recreational fishers will be directly impacted by the proposal (Figure 1).
As with our previous comments, our recommendation is that sustainably managed recreational fishing is allowed to occur
within the Marine National Park (IUCN Category II) Zone consistent with the current management arrangements in place in
IUCN Category II Commonwealth Marine Reserves in other regions.
The Western Australian government is committed to a South Coast Regional Management Plan (extending from Cape Leeuwin in
the west to the South Australian border in the east) (Government of WA, 2010).
Although not specifically part of the regional management plan, the development of marine protected areas in WA state waters
adjacent to the South-West Corner and Eastern Recherche Commonwealth Marine Reserves is possible and candidate areas for
marine parks have previously been identified by the Marine Parks and Reserves Selection Working Group (CALM, 1994).
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It is then vital that any zoning within the eastern part of the South-west Corner and the Eastern Recherche Reserves considers
the impacts of marine park planning in state waters, especially with regards to displacement of fishing effort arising from
complementary zoning within state waters.
Great Australian Bight Extension Commonwealth Marine Reserve
Figure 2. Great Australian Bight Extension and Western Eyre proposed Commonwealth marine reserve zoning with core recreational fishing areas identified.
While we are supportive of the extension of the marine reserve boundaries for the Great Australia Bight Extension Marine
Reserve, we do not support the proposed Marine National Park Zone (Figure 2) as long as recreational fishing is a prohibited
activity within this zone. The proposed Marine National Park (IUCN II) Zone within the GAB Extension Marine Reserve covers an
area currently designated as Multiple Use Zone (IUCN VI) within the existing Great Australia Bight (Commonwealth Waters)
Marine Reserve and would effectively rezone an area which is currently accessed by recreational fishers and ban their activity
within the zone. The main purpose of the existing zone (IUCN VI) is to protect calving habitat for Southern Right Whales and
Australian Sea Lion colonies. Existing conservation measures also include a 6 month closure to all forms of fishing between 1
May and 31 October. Within the adjacent South Australia Great Australian Bight State Marine Park, a Sanctuary Zone extending
from Mean Low Water Mark to 1 nautical mile offshore prohibits recreational fishing from a boat.
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Recreational boat fishing is therefore only allowed from between 1 nautical mile and 3 nautical miles offshore in the Great
Australia Bight Marine Park Conservation Zone and is also subject to the 1 May to 21 October closure effectively reducing
recreational fishing opportunities in this region to a narrow strip of water only accesible for six months of the year.
The current zoning arrangement and existing closures already provide more than adequate protection for the major
conservation values of this region considering that recreational fishing does not impact on whale calving or seal colonies in any
way possible.
Any further proposed adjustments to the zoning in the area contravene the following principles:
1. MPAs will be located taking into account the occurrence and location of existing spatial management arrangements (e.g.
existing protected areas and sectoral measures) that contribute to the goals.
9. Socio-economic costs should be minimised.
We are also mindful of the current marine park planning processes underway in South Australia state waters and the uncertain
impact of that process on recreational fishing. Any proposed restrictions on recreational fishing along the State/Commonwealth
Waters boundary (typically 3 nautical miles but up to 15nm in this region) will be expected to have a significant impact on
current and future recreational fishing opportunities in the region. It is our recommendation that if DSEWPaC continues to
ignore precedent and seeks to completely ban recreational fishing from Marine National Park (IUCN II) zones, then it would be
preferable to locate such zones further offshore where the impact on recreational fishers will be reduced.
Western Eyre Commonwealth Marine Reserve
The same issues mentioned for the GAB Extension also pertain the Western Eyre Commonwealth Marine Reserve with two
Marine National Park Zones likely to impact on recreational fishers (Figure 2). Our recommendation is that sustainably
managed recreational fishing is allowed to occur within the Marine National Park (IUCN Category II) Zones consistent with the
current management arrangements in place in IUCN Category II Commonwealth Marine Reserves in other regions.
Western Kangaroo Island Commonwealth Marine Reserve
Although recreational fishing will be allowed to continue within the proposed Western Kangaroo Island Commonwealth Marine
Reserve, we are concerned about the displacement of commercial fishing effort as well as the potential incremental impact of
complementary marine park zoning within South Australia state waters. Kangaroo Island and surrounding waters account for
over 40% of South Australia’s recreational fishing effort (Jones 2009) and the area is extremely important to recreational fishers
and charter operators.
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RECOMMENDATIONS AND CONCLUSIONS
RECOMMENDATIONS:
Recommendation 1.
We do not believe that it is the responsibility of the state/territory fisheries management agencies to
deal with impacts caused by the displacement of fishing activities as a result of Commonwealth MPA declarations and
zoning and recommend that this expectation is removed from the Fisheries Adjustment Policy.
Recommendation 2.
We recommend that independent researchers must be used to conduct the social and economic
analysis mentioned in the Fisheries Adjustment Policy and that such analysis must include the recreational fishing and
boating sectors.
Recommendation 3.
We recommend that any reference to a presumed growth in recreational fishing is reconsidered and
reference is made to the decreasing recreational fishing effort as demonstrated in the latest reports on recreational fishing
in the South-west Marine Region.
Recommendation 4.
The rationale for considering fishing (extraction of living resources) a pressure of potential concern is
revised in light of progress made in the last decade towards Ecosystem Based Fisheries Management. A broader list of
references must be included (i.e. Hall and Wise 2011; Penn and Fletcher 2010) that reflects the sustainable fisheries
management practises currently in place in these jurisdictions.
Recommendation 5.
We strongly recommend that additional explanatory notes or definitions are provided in the Plan that
clearly describe the variety of fishing activities that occur and their associated risks. In particular, definitions of the
pressures posed by recreational and commercial fishing activities must clearly distinguish between the two different sectors
and different fishing activities. A definition for charter fishing should also be included that clearly identifies the tourism
aspect of charter fishing operations.
Recommendation 6.
We recommend that the rationale for considering fishing as an impact of potential concern is revised
to remove reference to the tenuous claim that fishing for pelagic species can impact seabirds.
Recommendation 7.
We recommend that either evidence is provided to support the claim of increasing recreational and
commercial boating in the South west Region or else the statement is deleted.
Recommendation 8.
We, therefore recommend that any management plan for the South-west Marine Region must
consider the management and mitigation of anthropogenic sources of habitat modification and pollution and develop, in
consultation with the State authorities, a “ridge to reef” action plan to address these concerns.
Recommendation 9.
It is vital that this Marine Bioregional Planning process considers what impact complementary state
marine parks will have on users of the marine environment, particularly in terms of displaced commercial and recreational
fishing effort.
Recommendation 10.
We recommend that Section 3 of the Network Proposal on integrating social and economic
considerations is greatly expanded commensurate with the importance of this aspect of marine park planning. Further
detail needs to be provided about how impacts will be assessed and what adjustment measures will be offered to affected
individuals and communities.
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Recommendation 11.
We strongly recommend that the Australian Government precedent for allowing sustainably managed
recreational fishing within Marine National Park (IUCN II) Zones is continued in the South-west Marine Region subject to
criteria developed in conjunction with State Government Fisheries departments and the recreational fishing industry.
Recommendation 12.
For each proposed reserve, sustainably managed recreational fishing should be allowed to occur
within the Marine National Park (IUCN Category II) Zones consistent with the current management arrangements in place in
IUCN Category II Commonwealth Marine Reserves in other Marine Regions.
Recommendation 13.
The requirement for charter fishing activities to be subject to approval in General Use and Special
Purpose Zones is reviewed and consideration is given to recognising existing license or permit arrangements under state
fisheries legislation for these circumstances.
CONCLUSIONS:
The
Boating and Fishing Council of Australia
is fully committed to the principles of Ecologically Sustainable
Development. With direct reliance on healthy ecosystems and sustainable management of natural resources, it is in the best
interest of our industries and our customers that we support appropriate conservation measures that provide the means to
protect our marine ecosystems for future generations. We are however, pragmatic and believe that it is vital that management
of our marine environment requires a complete understanding of how different activities impact the environment in different
ways and how different users relate to the marine environment. It is not possible to consider recreational, charter and
commercial fishing under the single banner of “Extraction of living resources” without giving due consideration to the significant
differences between the three sectors and the great variety of fishing activities captured under such a broad heading.
Management of the marine environment needs to consider not only current usage but also potential future requirements for (in
the case of recreational and charter fishing) access to new experiences and sustainable recreational opportunities. Simply
because an area is not accessed today does not mean that there is no intention to visit the area in the future and with advances
in safe, efficient vessels, the recreational fishers of the future may well be able to access remote locations in a sustainable
manner and indeed, may spend significant periods of time at those locations.
The impact of marine planning and zoning leads inevitably to displacement of activity (especially commercial fishing) and it is
essential that the effect of this displacement on other users including recreational and charter fishers is accurately assessed and
accounted for. The aim of any marine reserve network must be to minimise the displacement of existing activities. We are
extremely concerned about the Australian Government’s apparent intent to ban activities that were previously allowed in IUCN
II zones in other Marine Regions. This position highlights significant inconsistencies with the legislated principles for managing
activities within marine park zones according to internationally recognised IUCN Criteria. We can find no evidence, valid reasons
or national and even international precedents as to why recreational fishing should be banned from Marine National Park (IUCN
II) Zones. In fact, we are of the opinion that ongoing access to Marine National Park (IUCN II) Zones by recreational fishers under
appropriate management arrangements consistent with IUCN II objectives can be extremely beneficial in promoting marine
conservation and fostering environmental stewardship in coastal communities.
On the issue of governance of MPAs, the Worldfish Centre (2008) in their “lessons learned” paper encouraged authorities to
embrace an approach to MPA management that emphasised co-management. Co-management with key stakeholders such as
the recreational fishing and boating community is vitally important if MPAs are to meet their management objectives, and
dictatorial “Fortress Conservation” management should be avoided at all costs (Diggles 2011).
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Indeed, it is questionable that the Federal Government will be able to effectively manage the proposed MPA networks without
significant stakeholder support, given their enormous size and the fact that even small, State managed MPAs in Australia have
failed to meet their management objectives (Diggles 2011). For example, the verdict of the Victorian Auditor General (2011)
relating to administration of MPAs in Victoria was scathing. The Auditor General report stated “Parks Victoria could not
demonstrate that it is effectively managing MPAs or that it is being effective or efficient in protecting marine biodiversity within
MPAs. An absence of regular risk assessment review, detailed action plans and a lack of evaluation—both of management plans
and activities—undermine planning at the park level”.
The Boating and Fishing Council of Australia is firmly committed to the concept of co-management and believes that it is vital
that all members of the community are involved in the management of marine reserves in the South-west Marine Region.
Indeed, key stakeholders such as recreational fishers provide invaluable eyes on the water and often provide authorities with
early warnings on issues that can damage biodiversity such as pollution and illegal fishing. The recreational fishing and boating
community welcome this opportunity to comment on the draft plan and proposed Commonwealth Marine Reserve network for
the South West Region and trust that this is the first step in ongoing and meaningful dialogue as industry and government work
together to achieve common goals for protection of biodiversity and maintenance of ecosystem health within our marine
environments.
CONTACT
Doug Joyner
Russell Conway
Executive Officer,
Chair,
Australian Fishing Trade Association
Recfish Australia
PO Box 5117
Ground Floor, Marine House
Elanora Heights NSW 2101
24 York Street
Phone: 02 99446210
Fax: 02 99131564
South Melbourne VIC 3205
Tel: 0419320843
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REFERENCES
Australian Bureau of Statistics (ABS) (2003). Chapter 17 – Forestry and fishing. 2003 Year Book Australia. No. 85 ABS Catalogue
No. 1301.0, Australian Bureau of Statistics, Canberra
Australian Bureau of Agricultural and Resource Economics – Bureau of Rural Sciences (ABARES-BRS) (2010). Australian fisheries
statistics 2009. ABARE-BRS and FRDC, Canberra
Australian Institute of Marine Science (AIMS) (2010). The AIMS Index of Marine Industry (2008-09), AIMS, Townsville 13pp.
Bunce A. & Norman F.I. (2000) Changes in the diet of the Australasian gannet (Morus serrator) in response to the 1998 mortality
of pilchards (Sardinops sagax). Marine and Freshwater Research 51, 349–353.
Dann P., Norman F.I., Cullen J.M., Neira F.J. & Chiaradia A. (2000) Mortality and breeding failure of little penguins, Eudyptula
minor, in Victoria, 1995-96, following a widespread mortality of pilchard, Sardinops sagax. Marine and Freshwater Research 51,
355–362.
Department of Conservation and Land Management (CALM) (1994). A Representative Marine Reserve System for Western
Australia: Report of the Marine Parks and Reserves Selection Working Group, Department of Conservation and Land
Management. Government of Western Australia, Perth
Department of Sustainability, Environment, Water, Population and Communities (2011). Overview of marine bioregional plans,
17pp.
Diggles, B.K (2011). The case for moderation of marine bioregional planning processes in Australia, A submission to the
Parliamentary Inquiry into the Environment Protection and Biodiversity Conservation Amendment (Bioregional Plans) Bill 2011.
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Government of Western Australia (2010). Oceans of opportunity: A proposed strategic framework for marine waters of Western
Australia’s south coast.
Hall, N.G. and Wise, B.S. (2011). Development of an ecosystem approach to the monitoring and management of Western
Australian fisheries. FRDC Report – Project 2005/063. Fisheries Research Report No. 215. Department of Fisheries, Western
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Hundloe, T. (2010) A Comprehensive ESD Analysis of a Fishery: the Incorporation of Regulatory, Ecological, Economical and
Sociological Aspects. FRDC Report – Project 2003/999, 39pp.
International Union for Conservation of Nature (2011). IUCN Protected Area Management Categories
http://www.iucn.org/about/work/programmes/pa/pa_products/wcpa_categories/pa_categoryii/
Jones, K. (2009). South Australian Recreational Fishing Survey. PIRSA Fisheries, Adelaide, 84 pp. South Australian Fisheries
Management Series Paper No 54.
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McPhee, D. (2011). Marine Park Planning and Recreational Fishing: Is the Science Lost at Sea? Case Studies from Australia,
International Journal of Science in Society, Vol 2, Number 2. http://science-society.com/journal/, ISSN 1836-6236
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Penn, J.W., Fletcher W.J. (2010). The efficacy of sanctuary areas for the management of fish stocks and biodiversity in WA
waters. Fisheries Research Report No. 169. Department of Fisheries, Western Australia. 48 pp.
Recfish Australia (2010). Recreational fishing in Commonwealth Waters: a preliminary assessment, Recfish Australia, Brisbane,
Australia 63 pp.
Recreational Fishing Advisory Committee (2011). Recreational fishing in Australia – 2011 and beyond: a national industry
development strategy. http://www.daff.gov.au/fisheries/recreational/rfids
Schrimer, J. and Casey, A.M. (2005). Social Assessment Handbook: a guide to methods and approaches for assessing the social
sustainability of fisheries in Australia. FRDC ESD Reporting and Assessment Subprogram Publication No. 7, FRDC, Canberra,
50pp.
Victorian Auditor General (2011). Environmental Management of Marine Protected Areas. Victorian Auditor General’s Report ,
March 2011. PP No 13, Session 2010-11. 30 pp.
Whittington R.J., Crockford M., Jordan D., Jones B. (2008). Herpesvirus that caused epizootic mortality in 1995 and 1998 in
pilchard, Sardinops sagax neopilchardus (Steindachner), in Australia is now endemic. Journal of Fish Diseases 31: 97-105.
WPCA (2000). Application of IUCN Protected Area Management Categories. Australian Handbook. http://www.unep-wcmcapps.org/protected_areas/categories/australia.pdf
Worldfish Centre (2008). Lessons learned and good practices in the management of coral reef marine protected areas.
http://www.reefbase.org/gefll/pdf/lessonslearnedMPAbrief_English.pdf
Web Links
http://www.environment.gov.au/coasts/mpa/southeast/activity.html
http://www.environment.gov.au/coasts/mpa/ningaloo/activities.html
http://www.environment.gov.au/coasts/mpa/ashmore/activities.html
http://www.environment.gov.au/coasts/mpa/elizabeth/activities.html
http://www.environment.gov.au/coasts/mpa/solitary/activities.html
http://www.unep-wcmc.org/protected_areas/categories/eng/ex-ii.pdf
http://wwf.panda.org/what_we_do/footprint/smart_fishing/target_fisheries/bluefin_tuna/tracking_the_giants/